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other than Ms. Maxwell might have been at the same place at the same time. It's just, you know, a happenstance they were in the same place and that's not admissible. Well, your Honor will notice in our opening brief on this, at pages 15 I think

through the next ten pages or so, we've gone through with a

chart and we've said, okay, here's the question we asked, and then in the right-hand column of our chart we put in the

witnesses and, you know, the flight logs. I know other things

that your Honor is very familiar with. This is why we're asking these questions. You know, the flight logs have been talked about over and over again, but for good reason. Kellen

is on some of these flight logs, and what's up? Those are the

questions that we asked, and of course she takes the Fifth. There are other things as well. For example, Sarah Ransome testified, I witnessed with my own two eyes Sarah Kellen reporting to Ghislaine in front of me, but I can't remember specifics. They weren't talking about girls. I can't

remember the specific conversation, but every single person,

100 percent, 200 percent, reported to Ghislaine. Later on in

that same deposition -- that was at page 288 and thereabouts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Sarah

Kellen, Leslie Groff, and Ghislaine Maxwell. Ghislaine was the

main lady. So again, we have an allegation by our client that

Ms. Maxwell was a part of a larger conspiracy. That's one of

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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